To consider this CCP free idea,... The team must do the homework, science based, industry standards, government standards, all potential risks to the end user, and super strong documented pre-requisite programs . It is totally possible, but you better have the solid evidence and validation to back it up. I am a cynic too because I see that wolf looking attorney ready to show that little child in the hospital with tubes all over the place ,......on a power point for the jury to galk at , with your weak looking HACCP plan. Be very carefull

It is possible. We do not have any CCP's in our process. We make food grade oils which are inherently safe and throughout the system have enough prerequisite programs that deem it unnecessary to have a CCP. There is no point in our process that is so critical it would cause a health issue if it failed because we have other controls down the line that would catch the problem.

HACCP is prevention. Meaning a sustainable control system must be taken into consideration.

Since control measures are divided into three (1) PRP (2) OPRP and (3)CCP. The basic requirement which is PRP must be put into place in order to achieve a zero CCP. Furthermore, a simple process and automated manufacturing equipment could also help in achieving a zero CCP.

I've recently taken over responsibility for the company's HACCP system and it was immediately clear how unfocused and paperwork based the system is. We have five CCPs which, increasingly and the more I study them, seem like CPs at best, or, actually monitoring systems. It seems like our whole food safety system best managed through prerequisites etc.

I mean, three out of the five are actually offline microbiological tests!!

I've recently taken over responsibility for the company's HACCP system and it was immediately clear how unfocused and paperwork based the system is. We have five CCPs which, increasingly and the more I study them, seem like CPs at best, or, actually monitoring systems. It seems like our whole food safety system best managed through prerequisites etc.

I mean, three out of the five are actually offline microbiological tests!!

Dear chrisbird,

IMEX, multiplicity often relates to the age of the haccp plan. And sometimes QA protective instincts regarding workload claims.

This was also my impression, seems like our HACCP 'plan' has been drawn up almost as a palimpsest of various studies, one added on top of the other but without a coherent review of the system as a whole.

I would argue an offline microbiological test can never be a CCP as it would require you to hold all product until the test passes but also it makes a (very big) assumption that the product is homogenous which is unlikely.

I, too , have just moved to a business which currently has 5 CCPs and I am proposing to change all to CPs controlled by PRPs. To say I have had some interesting comments would be an understatement.....

in HACCP, you have to conduct a hazard analysis after considering all the potential hazard significant to food safety and the determining control measures.

CCP -Critical Control Point . A step or point at which control can be applied and is essential to eliminating, preventing or reducing the hazard to acceptable levels.

Where food processing is concerned, I don not think it can be possible to have no CCPs in a HACCP plan, more especial on pathogenic hazards which can be controlled through CCPs such as chlorination and temperature CCPs.

Some years ago we changed our plan from 3 to 2 CCP's. Sometimes I think it would be easier to have at least 1 CCP = to avoid very difficult discussion with auditors. Not all auditors share the same ideas even though they work for the same CI.

Let us go to basics. CCP is an operational step which can do any of following

1) Eliminate Hazard

2) Reduce the hazards to acceptable limit or

3) Prevent hazard from getting introduced into food.

And it has to be last control for that identified significant Hazard.

Typically we have 3 types of hazards in food :

!) Biological

2) Physical; and

3) Chemical

Any operation in food processing which is performing first 3 activity and is last control will be CCP hence if we goby this typically we should have 1 CCP for each if in our process all 3 types of hazards are eliminated.

Further if we do not have any operation which eliminates/ reduce or prevents hazards then we will not be having any CCP with us hence no HACCP Plan this is why now FSMS- ISO22000 in general statement says :

7. Planning and Realization of Safe Product

7.1 General

The organization shall plan and develop the processes needed for realization of safe products.

The organization shall implement, operate and ensure the effectiveness of the planned activities and any changes to activities. This includes PRP(s) as well operational PRP(s) and/or the HACCP plan.

Technically, we don't have a CCP in our HACCP Plan but during the BRC IOP Pre-assessment, the auditor suggested that we include at least 1 CCP just to 'get the feel' of it so we revised the HACCP plan with one CCP. The thing is, it is not really a CCP according to the definition so during the initial audit, the auditor (a different one) asked how come we had that CCP and I explained that it was just a 'practice' thing. During the next HACCP review, the next move would be to 'eliminate' that one CCP.

Our HACCP plan has no CCP's due to the fact it is a small company that copacks/repacks. No blending, mixing etc. Product in, repacked, product out. Limited exposure. The facility even had several inspectors say there are no CCP's. My question is where can we find supporting literature for this decision?

It is absolutely possible. A Haccp plan is unique to your process and should never be approached with preconceived notions of what it should have in it. Starting out thinking you need to have CCP's will lead you to possibly call something a CCP that really isn't. Follow the steps and think it through.

Our HACCP plan has no CCP's due to the fact it is a small company that copacks/repacks. No blending, mixing etc. Product in, repacked, product out. Limited exposure. The facility even had several inspectors say there are no CCP's. My question is where can we find supporting literature for this decision?

Hi Cheryl,

A belated welcome to the forum.

In a discussion recently on HACCP, an auditor recently commented that it was his opinion that a CCP really meant that the system was still not under complete control. The reality is that many processes do have places where there is a need for a more intense control. But there is no maximum or minimum requirement on CCP's. I once had a corporate HACCP plant with 7 or 8 CCP's that was a nightmare, and auditors were aghast at how many we had and that they were not truly CCP's but CP's. While it may be common knowledge that a CCP is not a requirement it is difficult to find documentation. Will do a bit more research.

Someone may have said this in a previous post, the ugly truth is most auditors will be put at ease with a CCP or two in a plan. If you have none, audit scrutiny is high. If you have a lot, audit scrutiny is high. If you have one or two, audit scrutiny is juuuuust right*.

Have I ever told you the story of the Three Auditors? The big customer auditor said, "It is tooooo cold!" The certifying auditor said, "It's tooooo hot." Then the little customer auditor said, "It is JUUUUUST right!" And somehow, as if by magic, we got all of them quiet.